S. Ravindra Bhat, J.

1. The assessee in this appeal questions the decision of the Income Tax Appellate Tribunal (ITAT) by which the Revenue’s appeal was allowed for the assessment year (AY) 1996-97.

2. The substantial question of law framed for consideration by this Court is as follows:

“Did the Tribunal fall into an error in holding that the assessee had not discharged the initial onus cast upon it under Section 68 and furnishing satisfactory explanation in respect of the total amount of Rs.29,70,900/- in the facts and circumstances of the case?”

3. The assessee company was engaged in manufacturing of cotton buds and cotton balls. Since its business was not running profitably, it took up the business of consultancy in real estate development. During the concerned assessment year, the Assessing Officer (AO) noted that the assessee had received two amounts from two Non-Resident Indians (NRIs). The first was from Vinay Kumar Kedia (an amount of Rs.14,97,400/-), and the second was from Sh. Narottam Singh (an amount of Rs.14,73,410/-). During the course of enquiry, the assessee said that these amounts were received for purchase of land on behalf of these NRIs. The AO observed tha